DBPS Law Firm

24/02/2026

The (SC) En Banc, during its session today, July 25, 2025, has declared the Articles of Impeachment against Vice President Sara Z. Duterte unconstitutional, noting that it is barred by the one-year rule under Article XI, Section 3(5) of the Constitution and that it violates the right to due process enshrined in the Bill of Rights. Therefore, the Senate could not acquire jurisdiction over the impeachment proceedings.

However, the SC said it is not absolving Vice President Duterte from any of the charges against her. But any subsequent impeachment complaint may only be filed starting February 6, 2026.

The ruling of the SC is immediately executory. It shall be deemed served on the petitioners and promulgated upon publication in the SC website and receipt of the parties of their digital copy in accordance with A.M. No. 25-05-16-SC or the Guidelines on the Transition to Electronic Filing in the Supreme Court.

The case stemmed from four impeachment complaints against Vice President Duterte. The first three were filed before the House of Representatives (HOR) by private individuals and different groups on December 2, 4, and 19, 2024.

A fourth complaint was lodged by a resolution approved by more than one-third of the HOR members of the 19th Congress on February 5, 2025, which was transmitted as the Articles of Impeachment to the Senate on the same day. This was followed by two petitions filed before the SC challenging its constitutionality.

The SC voted 13-0-2, with the Justices present voting unanimously to grant the petitions to annul the Articles of Impeachment, and Justice Alfredo Benjamin S. Caguioa inhibiting and Justice Maria Filomena D. Singh on leave.

The Decision, written by Senior Associate Justice Marvic M.V.F. Leonen, ruled that all legal issues involving impeachment proceedings are subject to judicial review, “considering the nature of the offices and the institutions that are subject to impeachment, its effect on the independence of constitutional departments and organs, and its nature as a constitutional process.”

In declaring that the Articles of Impeachment were barred by the one-year rule, the Decision differentiated the first three complaints from the fourth complaint. The first three, it said, were filed under Article XI, Section 3(2) of the Constitution which allows any citizen to file a verified complaint with an endorsement by any HOR member. The fourth one was through Article XI, Section 3(4) of the Constitution through a verified complaint or resolution filed by at least one-third of the HOR members.

The SC took note that the HOR in the 19th Congress did not act on the first three endorsed complaints, which were considered “terminated or dismissed” upon the adjournment of the HOR.

The SC also determined that due process applies to the impeachment process. It laid down the following due process requirements in impeachment proceedings:

1. The Articles of Impeachment or resolution must include evidence when shared with HOR members, especially those who are considering its endorsement.

2. The evidence should be sufficient to prove the charges in the Articles of Impeachment.

3. The Articles of Impeachment and the supporting evidence should be available to all members of the HOR, not only those who are being considered to endorse.

4. The respondent in the impeachment complaint should have been given a chance to be heard on the Articles of Impeachment and the supporting evidence to prove the charges prior to its transmittal to the Senate, despite the number of endorsements from HOR members.

5. The HOR must be given a reasonable time to reach their independent decision of whether they will endorse an impeachment complaint. The SC, however, has the power to review whether this period is sufficient, but petitioner—who invokes the SC’s power to review—should prove that officials failed to perform their duties properly.

6. The basis of any charge must be for impeachable acts or omissions committed in relation to their office and during the current term of the impeachable officer. For the President and Vice President, these acts must be sufficiently grave amounting to the crimes described in Article XI, Section 2 or a betrayal of public trust given by the majority of the electorate. For the other impeachable officers, the acts must be sufficiently grave that they undermine and outweigh the respect for their constitutional independence and autonomy.

7. To ensure that respondent in the impeachment complaint is heard, the HOR is required to:

(a) Provide a copy of the Articles of Impeachment and its accompanying evidence to the respondent to give him/her an opportunity to respond within a reasonable period to be determined by the HOR rules. The Constitution only requires an opportunity to be heard. It is up the respondent to waive this fundamental right and opt to present his/her evidence at the Senate trial; and

(b) Make the Articles of Impeachment, with its accompanying evidence and the comment of the respondent, available to all the members of the HOR. It is the HOR—not one-third of the HOR—that has the sole prerogative to initiate impeachment complaints. Thus, there must be some modicum of deliberation so that each member representing their constituents can be heard and thus convince others of their position. The transmittal however will only take place upon the qualified vote of one-third of the HOR.

Read the full text of the Press Release at https://tinyurl.com/596r7cde.

Read the full text of the Decision at https://tinyurl.com/xukhchaf

Read the Separate Concurring Opinion of Justice Ramon Paul L. Hernando at https://tinyurl.com/3cjtcpjv.

Read the Separate Concurring Opinion of Justice Henri Jean Paul B. Inting at https://tinyurl.com/3wdhk52w.

Read the Separate Concurring Opinion of Justice Rodil V. Zalameda at https://tinyurl.com/mr47p9ux.

Read the Separate Concurring Opinion of Justice Jhosep Y. Lopez at https://tinyurl.com/mr22rane.

Read the Concurring Opinion of Justice Samuel H. Gaerlan at https://tinyurl.com/u9um2h54.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has affirmed the authority of the National Labor Relations Commission (NLRC) to execute the terms of a Collective Bargaining Agreement (CBA) in cases involving unfair labor practices (ULP).

In a Decision written by Associate Justice Japar B. Dimaampao, the SC’s Third Division upheld the NLRC’s order directing Guagua National Colleges (GNC) to pay its employees the agreed economic benefits, but adjusted how those benefits were computed.

The case arose from negotiations in 2009 to renew the five-year CBA between GNC and its unions. Although GNC agreed to provide benefits such as a rice subsidy, loyalty pay, and clothing allowance, it continued to delay signing the draft CBA. Frustrated, the unions filed a notice of strike.

The NLRC ruled that GNC bargained in bad faith, which is an unfair labor practice. It also declared the final CBA draft as the parties’ agreement. NLRC ordered GNC to pay its employees the agreed benefits covering 2009 up to the present date, which at that time was 2017.

GNC questioned the order directing them to pay, arguing that only voluntary arbitrators—not the NLRC—had the power to enforce the CBA terms.

Upholding the authority of the NLRC, the SC clarified that while voluntary arbitrators generally handle CBA implementation, the Labor Code authorizes the NLRC to enforce CBA provisions when gross violations amounting to ULP are involved.

The SC said that in this case, it was the NLRC which was best positioned to enforce the CBA, having reviewed it. Sending the case to voluntary arbitrators for implementation would only cause delays, increase the likelihood of multiple lawsuits, and prolong the resolution of rights and obligations between the parties.

However, the SC ruled that the computation of benefits was incorrect. It held that the computation should exclude the signing bonus and cover only the five-year CBA term, or the years 2009 to 2014.

Read the full text of the Press Release at https://tinyurl.com/3j53bt6j.

Read the full text of the Decision at https://tinyurl.com/yc46kjar.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has clarified that being listed in a corporation’s General Information Sheet (GIS) is not enough to prove someone is a stockholder.

In a Resolution written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division granted a motion for reconsideration of its earlier Decision and ruled that Ma. Christina Patricia C. Lopez (Christina) and John Rusty Lito Lopez (John Rusty) are not stockholders of LC Lopez and Conqueror, despite being listed in the companies’ GIS submitted to the Securities and Exchange Commission.

The case stemmed from special stockholders’ meetings held by the two companies to elect new board members. Christina and John Rusty sent proxies to participate, but the companies rejected them, stating that their principals were not registered stockholders. The meetings proceeded, and new directors were elected.

Christina and John Rusty challenged the elections before the Regional Trial Court (RTC), arguing that their exclusion invalidated the election due to a lack of quorum. The RTC ruled in their favor, relying on the GIS as proof of their stockholder status.

However, the Court of Appeals reversed the RTC’s decision, pointing out that their names did not appear in the companies’ stock and transfer books.

The SC initially upheld the RTC’s decision, considering the GIS and witness testimonies as sufficient evidence. Respondent board of directors, however, moved for reconsideration.

In granting the motion, the SC clarified that the stock and transfer book is the primary and official record of a corporation’s stockholders. A person must also present a stock certification issued in their name to prove ownership of shares.

Under Section 62 of the Revised Corporation Code, a transfer of shares is not valid—except between the parties—until it is properly recorded in the company's books.

The SC ruled that being listed in the GIS does not make one a stockholder, and that the stock and transfer book prevails.

Read the full text of the Press Release at https://tinyurl.com/35m52bke.

Read the full text of the Resolution at https://tinyurl.com/5n75bf7s.

Read the Dissenting Opinion of Associate Justice Ricardo R. Rosario at https://tinyurl.com/a5jwrd4d.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

24/02/2026

The (SC) has ruled that a Special Power of Attorney (SPA) automatically ceases upon the death of the person who granted it, and any acts carried out by the agent afterwards are void, unless covered by narrow exceptions under the law.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division held that Jessica Alova Uberas lost her authority under the SPA to act on behalf of her father, Meliton Alova, upon his death in 1998.

In 1998, Meliton executed an SPA in favor of Jessica over the subject conjugal property. He died later that year. Despite the death of his father, Jessica still used the same SPA in 2003 to execute a mortgage over the said property in favor of San Miguel Foods, Inc. (SMFI) to secure her loan from the company. Jessica failed to pay the loan and the property was foreclosed where SMFI emerged as the winning bidder.

Felicidad Alova and Decelyn Alova Pution, the widow and other daughter of Meliton, filed a case to nullify the mortgage and the foreclosure sale.

Both the Regional Trial Court (RTC) and the Court of Appeals (CA) determined that Meliton’s death ended the agency. However, the RTC found that because the SPA had the conformity of Felicidad, Meliton’s wife, the mortgage was valid on her ½ share of the conjugal property. On the other hand, the CA declared the mortgage invalid, citing that it was not executed on behalf of Spouses Meliton and Felicidad.

SMFI appealed to the SC, which partly ruled in its favor. The Court upheld the agency’s termination but validated the mortgage and foreclosure sale with respect to Jessica’s undivided share in the property.

The SC explained that under an SPA, which is a contract of agency, a principal authorizes an agent to act on his or her behalf in transactions with third persons. Agency is personal, representative, and derivative, and it ends upon the death of either the principal or the agent.

Any act by the agent after the principal’s death is void, unless it falls under two Civil Code exceptions: (1) when the agency was for the parties’ common interest, and (2) when the agent, unaware of the death or agency’s end, contracted with a third party in good faith.

In this case, there was no showing that these exceptions were applicable. Jessica was fully aware of her father’s death, and the SPA was not made for their mutual benefit.

The SC also reiterated that for an agent’s act to bind the principal, the deed must clearly be made, signed, and sealed in the principal’s name.

Here, although Jessica was described in the beginning of the deed as Meliton’s attorney-in-fact, the mortgage was signed by Jessica in her personal capacity, as it was neither executed nor sealed in Meliton’s name, and without indication that she was acting as attorney-in-fact.

The Court also ruled that Meliton’s wife, Felicidad, was not bound as a principal under the SPA, as she only provided her marital conformity.

However, the Court clarified that the mortgage and foreclosure sale were not entirely void. Jessica automatically became a co-owner of the property after her father’s death. When she signed the mortgage, she encumbered her share in the property to secure her obligation to SMFI. Therefore, the mortgage and foreclosure sale were valid only for Jessica’s share.

The Court remanded the case to the RTC to determine Jessica’s share in the subject property and to annotate the shares of Meliton’s other heirs, and that of SMFI which acquired Jessica’s interest.

Read the full text of the press release at https://tinyurl.com/27t9k6vy

Read the full text of the Decision at https://sc.judiciary.gov.ph/260071-san-miguel-foods-inc-vs-felicidad-d-alova-and-decelyn-alova-pution/

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has reiterated the rules in determining the appropriate legal actions for recovery of possession and/or ownership of land and the corresponding prescriptive periods in filing them. These remedies are: 𝙖𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or ejectment, 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖, and 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

In a Decision written by Associate Justice Ricardo R. Rosario, the SC 𝙀𝙣 𝘽𝙖𝙣𝙘 held that Lea Victa-Espinosa (Espinosa) correctly filed an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 to recover possession of her land within a year from dispossession. It explained that 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 may be filed not only when the dispossession lasted for a year but also when it lasted for a year or less when there is no allegation that the deprivation is by force, intimidation, threat, strategy, or stealth.

The SC also ruled that Espinosa’s action is not 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 as she did not seek in her complaint the recovery of ownership of the land.

After purchasing the property, Espinosa found that Spouses Noel and Leny Agullo were occupying a part of it. When they refused to leave despite her demand, Espinosa filed a complaint for recovery of possession in the Regional Trial Court (RTC).

The RTC dismissed the complaint for being filed too early. It explained that Espinosa may still file forcible entry, an ejectment suit, within one year from the time she learned of the deprivation of physical possession of the land. Since an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 can only be filed after that one-year period, RTC ruled that her complaint was premature.

The Court of Appeals reversed the RTC’s decision, finding that Espinosa’s complaint was not an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 but an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖, as she sought to recover possession based on her ownership of the property.

In their Petition before the SC, Spouses Agullo sought to reinstate the ruling of the RTC dismissing the case and insisted that Espinosa’s case was an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 that was filed prematurely, as less than a year had passed since the alleged dispossession.

The Court denied the Petition but clarified that the action is not accion reivindicatoria but accion publiciana. It reiterated the actions available for recovery of possession and/or ownership of land:

• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or a summary ejectment case;
• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖; and
• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or summary ejectment proceeding is filed to recover physical possession of land when the dispossession was due to force, intimidation, threat, strategy, or stealth and has not lasted for more than a year.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 is filed when the dispossession lasted for more than a year, or even for a year or less, if it is not due to force, intimidation, or similar means.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 is filed to recover both ownership and possession based on that ownership.

The Court explained that in 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖, the issue is who has the better right to possess the land, without necessarily claiming ownership. In contrast, 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 involves determining who owns the land, with possession granted to the rightful owner.

As what is sought in the complaint is recovery of possession and not ownership, and there is no allegation that Spouses Agullo disputed Espinosa’s title, the action is 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 and not 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

The Court also held that contrary to the findings of the RTC, the action was not premature, because 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 may be filed even within one year from dispossession if no force, intimidation, threat, strategy, or stealth was used. Since Espinosa did not claim that Spouses Agullo used any of these means, the action was correctly filed not as ejectment suit but 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖.

The SC thus ordered the RTC to proceed to trial and decide the case.

Read the full text of the press release at https://tinyurl.com/y7nr9hzx

Read the full text of the Decision at https://tinyurl.com/38e2xzfa

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has ruled that a public institution must vacate the land it occupies if it lacks permission from the rightful owner and the owner has a better right of possession.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division ordered the Department of Education (DepEd) to vacate and return a parcel of land to its owner, Princess Joama Marcosa A. Caleda (Caleda).

In 2014, Caleda bought a 10,637 square meter rice land in Cagayan through an Extrajudicial Settlement of Estate with Waiver of Rights and Sale signed by the heirs of the registered owner, Bueno Gallebo (Gallebo).

However, when Caleda later visited the land for a relocation survey, she discovered that it was being occupied by the Solana Fresh Water Fishery School (the School), a public institution under DepEd Regional Office 2.

Caleda sent several demand letters for DepEd to vacate the land, but received no reply. She then filed a case to recover possession of the land and remove any structures built on it.

DepEd argued that government agencies cannot be evicted from land already used for public purposes. It claimed it had the right to take over the property through its power of eminent domain, and that Caleda’s only remedy was to ask for just compensation.

Ruling in favor of Caleda, the SC found that the latter had clearly proven her better right to the property. Her land title was valid and accurately described the land, unlike the School’s deed of sale, which referred to an adjacent lot.

The SC emphasized that while the government can take private property for public use through its power of eminent domain, this must be done through proper legal proceedings and with payment of just compensation. Because no expropriation process was initiated in this case, the School could not retain the land simply by offering to pay for it.

The SC also clarified that a public institution can only prevent eviction if the property owner fails to assert their rights in time, which is considered an implied acceptance.

In this case, Caleda acted quickly—sending demand letters, talking to DepEd, registering her claims, and filing a case within two years of discovering the School’s occupation of the property.

Read the full text of the Press Release at https://tinyurl.com/y35skjpf.

Read the full text of the Decision at https://tinyurl.com/58ja5trh.

24/02/2026

The (SC) has clarified that disputes involving condominium contracts should be decided by the Human Settlements Adjudication Commission (HSAC), formerly the Housing and Land Use Regulatory Board (HLURB), and not the Regional Trial Court (RTC).

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division nullified the RTC’s ruling that held Vivien M. Cadungog (Cadungog) and Sung Ha Jung (Sung) civilly liable to each other over a contract to sell involving a condominium unit.

Under the contract, Cadungog, a developer of a condominium building in Cebu City, agreed to deliver a unit to Sung once he completed payment of PHP 3.5 million. Sung paid a PHP 175,000 downpayment, and later PHP 3 million, leaving a balance of PHP 258,950. Because of the unpaid amount, Cadungog refused to deliver the unit.

Sung then filed a criminal complaint before the RTC against Cadungog, citing a violation of Presidential Decree No. (PD) 957 or the 𝘚𝘶𝘣𝘥𝘪𝘷𝘪𝘴𝘪𝘰𝘯 𝘢𝘯𝘥 𝘊𝘰𝘯𝘥𝘰𝘮𝘪𝘯𝘪𝘶𝘮 𝘉𝘶𝘺𝘦𝘳𝘴’ 𝘗𝘳𝘰𝘵𝘦𝘤𝘵𝘪𝘷𝘦 𝘋𝘦𝘤𝘳𝘦𝘦.

The RTC acquitted Cadungog, but ordered her to either: deliver the unit upon full payment of the purchase price, or return the amount Sung had already paid. Cadungog argued that it was the HLURB and not the RTC which had jurisdiction over the civil aspect of her case.

Ruling in Cadungog’s favor, the SC declared as null and void the RTC’s decision on the civil matter of the case.

It explained that while civil liability can be decided in a criminal case, this does not apply when the liability arises from a contract, as in this case.

The SC emphasized that the civil dispute between Cadungog and Sung stemmed from their contract to sell.

Further, under PD 957, as amended, the HLURB (now reconstituted as the HSAC) has exclusive jurisdiction over cases involving contractual and legal obligations between buyers and developers of real estate projects. At the time Sung filed the complaint, it was the HLURB that had authority over such cases.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=151440.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=151432.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has reiterated that banks may be held liable for moral damages suffered by depositors due to negligence, even if there is no proof of bad faith or malice.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division ordered Banco de Oro (BDO) to pay Remedios and Angelita Antonino (Antoninos) the proceeds of their time deposit, including PHP 100,000 in moral damages.

The Antoninos, who are U.S. green card holders living abroad, made three time deposit placements totaling over USD 150,000 at BDO’s San Lorenzo Branch in Makati City (BDO San Lorenzo). They had an arrangement with the branch manager that if the deposits were not withdrawn at maturity, they would automatically roll over into interest-bearing savings accounts. The time deposit certificates (TDCs) were not redeemed and were stored in a Banco Filipino deposit box for safekeeping.

Later, Banco Filipino declared bankruptcy and was taken over by the Philippine Deposit Insurance Corporation (PDIC). It took the Antoninos some time to retrieve their TDCs from the PDIC.
BDO San Lorenzo then ceased operations and closed down without notifying the Antoninos, who only discovered the closure when they tried to withdraw their investments.

They sent several demand letters to BDO, but the bank claimed the deposits had already been withdrawn, citing a demand draft allegedly signed by Angelita. Angelita denied signing the document.

The Antoninos filed a complaint against BDO seeking payment of their time deposit placements.

Ruling in favor of the Antoninos, the SC cited Section 9 of BDO’s terms and conditions for time deposit placements, which requires the surrender of TDCs when withdrawing deposits. Since the Antoninos still had the certificates, the SC concluded that the funds were not withdrawn.

The SC noted that the PNP expert said the signature on the demand draft was likely forged. Immigration and passport records also showed Angelita could not have been in the country to sign the draft. Further, BDO failed to verify the identity of the person who withdrew the funds.

The SC held that these lapses showed BDO’s failure to exercise the required diligence, especially given the large amount involved.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=152203.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=152187.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The (SC) has reiterated that preventing employees from entering company premises and doing their jobs, without a valid reason, is considered illegal dismissal.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division upheld the labor arbiters’ ruling that 12 workers from Constant Packaging Corporation (Constant Packaging), a company that prints packaging materials, were illegally dismissed.

Constant Packaging hired the workers as sorters and packers on a 𝘱𝘢𝘬𝘺𝘢𝘸 basis (paid per output).

The workers later raised concerns about their below-minimum wage earnings, 12-hour work day, 7-day work week, non-remittance of their SSS, PhilHealth, and PAG-IBIG contributions, and delay in the release of their salaries. Constant Packaging responded by telling them to leave if they were unhappy with their working conditions.

The workers filed a complaint with the Department of Labor and Employment. Soon after, the company security guard prevented them from entering the company premises, leading the workers to file a complaint for illegal dismissal.

Ruling in favor of the workers, the SC clarified that an employee who is able and willing to work is considered illegally dismissed if they are prevented from entering the workplace without a valid or lawful reason.

In this case, the company’s security guard blocked the workers from entering the company premises without any valid reason. This action amounts to dismissal.

Moreover, as the workers were suddenly dismissed without following the required procedures, their dismissal was unlawful.

The SC thus ordered Constant Packaging to pay the workers separation pay, back wages, service incentive leave, and holiday pay.

However, since the workers were hired on a 𝘱𝘢𝘬𝘺𝘢𝘸 basis, the SC ruled that they are not entitled to 13th month pay.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-preventing-employees-from-reporting-to-work-without-valid-reason-is-illegal-dismissal/.

Read the full text of the Decision at https://sc.judiciary.gov.ph?p=152126.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

24/02/2026

The has reiterated that just compensation in land expropriation cases must be based on all relevant factors, not just market value.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division remanded to the Regional Trial Court (RTC) the case between the City Government of Pasay (Pasay LGU) and Arellano University (University) to reassess the amount of just compensation owed to the latter.

The University filed a complaint before the RTC in 2015, claiming that the Pasay LGU took its 805-sq. m. parcel of land in Barangay San Isidro and turned it into a public road, now known as Menlo Street, without going through proper expropriation proceedings or paying just compensation. The parties subsequently referred the matter to a board of commissioners composed of Pasay LGU officials.

The board used a base value of PHP200/sq. m. based on the 1978 General Revision of the City Assessor’s Office, then added 6% annual interest from 1978, the year the street was discovered, up to 2017, resulting in a value of PHP2,060/sq. m.

The University disagreed and proposed a total compensation of PHP 5,793,664.63, arguing that the interest should be based on the rates published by the Bangko Sentral ng Pilipinas.

The RTC adopted the board’s base value but applied a different interest rate, ordering Pasay LGU to pay PHP 161,000 plus 12% annual interest from 1978 to 2018.

The CA remanded the case to the RTC, ruling that the RTC relied solely on the 1978 assessment and ignored other relevant factors.

The SC upheld the CA, finding that the RTC’s decision was based on incomplete data.

Article III, Section 9 of the Constitution provides that private property cannot be taken for public use without just compensation. The SC emphasized that just compensation must be real, substantial, full, and ample, and that determining this amount is a matter for the courts to decide.

The SC clarified that although local government assessors provide appraisals, these are not controlling in expropriation cases. Such appraisals often cover broad areas and do not account for specific property differences. They rely on general descriptions and may be inaccurate. And while tax values can serve as a guideline, they cannot substitute for a comprehensive assessment of just compensation.

Thus, courts must use a “totality of circumstances” approach, considering all facts about the property’s condition, surroundings, existing improvements, and capabilities. These include the zonal valuation of the Bureau of Internal Revenue, acquisition cost, tax declarations, size, shape, location, and the current value of similar properties.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=153762

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=153692

Read the Separate Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/?p=153737

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.